ML20195D952

Insp Repts 50-498/88-62 & 50-499/88-62 on 880912-14 & 881010-14.No Violations or Deviations Noted.Major Areas Inspected:Qc Program & Preoperational Test Procedure Review, & Test Witnessing & Location of Manual Trip Circuit

ML20195D952
Person / Time
Site:	South Texas
Issue date:	10/26/1988
From:	Bundy H, Mckernon T, Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20195D948	List: ML20195D944 ML20195D952
References
50-498-88-62, 50-499-88-62, NUDOCS 8811070201
Download: ML20195D952 (8)

See also: IR 05000498/1988062

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APPENDIX

U.S. NUCLEAR. REGULATORY COMMISSION

ItEGION IV

NRC Inspection Report: 50-498/88-62 Operating License: NPF-76

50-499/88-62 Construction Permit: CPPR-129

Dockets: 50-498

50-499

Licensee: Houston Lighting & Power Company (HL&P)

P.O. Box 1700

-Houston, Texas 77001

Facility Name: South Texas Project (STP), Units 1 and 2

Inspection At: STP, Matagorda County, Texas

Inspection Conducted

September 12-14, 1988 and October 10-14, 1988

Inspectors: !aN~

T. O. McKetp6n, ReactorJInspector. Test

/* he /rr

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Programs Section. Division of Reactor Safety

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H. F. BundyPReactor I'nspector, Test Programs Date

Section, Division of Reactor Safety

Approved: b ^- ^" Iclu /tt

W. C. Seidle,Mhief Test Programs Section Date

Division of Reactor Safety

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Inspection Summary

inspection Conducted October 10-14, 1988 (NRC Inspection Report 50-498/88-62)

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Area Inspected: Routine, unannounced inspection of followup to previously

l identified inspection concerns related to the quality control program.

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Results: Generally, the maintenance work request packages reviewed by the NRC

inspector satisfied the applicable requirements and were properly reviewed by

management for content and completeness. No violations or deviations were

identified; however, an unresolved item concerning maintenance practices

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relative to Unit I was identified, (paragraph 5).

' Inspection Conducted September 12-14, 1988 (NRC Inspection Report 50-499/88-62)

Areas inspected: Routine, unannounced inspection of preoperational test

procedure review, preoperational test witnessing, location of manual trip

circuit, and fuel receipt.

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Results: Procedures reviewed satisfied applicable requirements. The

l preoperational testing witnessed by the NRC inspectors was performed in

accordance with the licensee's administrative procedures. The manual trip

circuit was correctly located to perform its intended function. Fuel receipt

was properly performed in accordance with licensee procedures. No violations

or deviations were identified.

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DETAILS

1. Persons contacted

HL&P

J. Westermeier, STP General Manager

• S. Head, Supervisor Project Engineer

K. O'Gara, Project Compliance Engineer

• M. Polishak, Lead Engineer, Project Compliance Group

0. Porter, Startup Engineer

D. Wahlhoim Startup Engineer

R. Thorin, Startup Engineer

B. Bealfield, Maintenance Technical Supervisor

• • P. L. Walker, Licensing

• • D. N. Brown, Construction

• • W. J. Jump, Maintenance 'apervisor

• • J. D. Green, Inspection and Surveillance Manager

• • M. A. McBurnett, Licensing Manager

• • M. R. Wisenberg, Plant Superintendent

NRC

D. Hunnicutt Senior Project Engineer

J. Tapia, Senior Resident Inspector, Unit 2 '

J. Bess Senior Resident Inspector, Unit 1

"'*L. J. Callan, Director, Division of Reactor Projects, Rty

• • E. Holler, Chief, ORP/D. RIV

The NRC inspectors also interviewed other licensee employees during the

inspection.

• Denotes those attending informal exit interview held on September 14,

1988. A fonnal exit interview was not held at the conclusion of the

inspection of September 12-14, 1988, because of personnel unavailability

due to the Hurricane Gilbert watch.

• • Denotes those attending exit interview conducted on October 14, 1988.

2. Preoperational Test Procedure Review (70346)

The NRC inspector reviewed the following procedure to determine that it

satisfied regulatory requirements, final safety analysis report (FSAR)

comitments and industry standards.

2HF-P-02 Revision 0. TCN 1. "FHB HEPA/ Charcoal Filter Test"

It was also determined that it complied with licensee administrative

procedures.

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No violations or deviations were identified in the review of this program '

area.

3. Preoperational Test Witnessing (70446) ,

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The NRC inspector witnessed completion of portions of the following test:

2HE-P-01, Revision 0. TCN 4. "EAB HVAC System"

Activities witnessed were perfomed in accordance with the Test Procedure l

and Startup Administrative Instruction 18 Revision 7. "Preoperational '

Testing."

No violations or deviations were identified in the review of this program

area.

4. Location of Manual Trip Circuits (TI2500/14)

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The purpose of this part of the inspection was to confim the correct  !

location of the manual reactor trip circuits which are located downstream [

of Output Transistors 03 and Q4 in the UV output circuit. This will

prevent short-circuit failures of the automatic tripping of the associated

reactor trip breakers as described in NRC Infomation Notice 85-18. The

NRC inspector confirmed the correct location of the manual trip circuits

for both units from Bechtel Drawings 14926-0387(1)00171-BWN/ ,

14926-0387(2)00171-BWNand 14926-0387(1)00172-BWN/14926-0387(2)00172-BWN.

No violations or deviations were identified in the review of this program l

area.

5. Followup to Previous Inspection Findings (92701) .

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This portion of the inspection involved the followup to quality control 1

(QC) program concerns which, in part, were addressed in NRC Inspection

Report 50-498/88-52;50-499/88-52. The main effort of this inspection was

focused upon the review of maintenance work request packages (MWRs) for

adequate QC instructions, inspections, and reviews. The MWRs listed in -

the attachment represent a review sampling of MWRs completed between March

and August 1988. In the sample, greater weight was given to selecting  ;

PWRs completed during August 1988.  ;

During the review of the MWR packages, the NRC inspector noted that the i

licensee is effectively applying the requirements of ANSI N18.7-1976. To t

that effort, the licensee has established a program for the inspection of I

activities affecting safety. Inspections, examinations, measurenents,

etc., are perfortned by qualified individuals in accordance with the l

requirements of ANSI N45.2.6. In those instances, where inspections are  ;

to be perfomed by qualified individuals other than the craftsmen perfoming i

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the work, inspections are performed by the appropriate maintenance supervisor,

systems engineer, or QC inspector. Generally, these practices are evidenced

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by incorporation of independent verification hold points, maintenance i

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verification points (MVPs), quality verification / notation points (QVPs, '

QNPs), and quality inspection points (QIPs) into the work instructions.

i Although not all maintenance procedures contained the above types of

inspection hold points, the procedures generally provided evidence of a

i QC inspection sampling methodology. Applicable procedures, drawings,  ;

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specifications, standards, codes, and acceptance criteria were either

specifically stated in the MWR package or specifically referenced. The

work instructions indicated that the first-line craf tsmen and maintenance

section supervisors have responsibility for proper maintenance implementation

and cleanliness preservation. QC inspections (QNPs, QVPs, QIPs) are "

designated and incorporated into maintenance instructions during the

maintenance procedure development. Determination of the specific types of r

QC inspections (e.g., torquing, cleanliness, clearances, lockwiring.

4 etc.) and their frequency is established by the QC department. The QC l

department makes the determinations based upon QC inspector availability,  ;

i QC inspection essentit.lity, and problem trending. QC inspection instructions t

4 are either specifically stated in the maintenance procedures or specific  !

reference is made to vendor technical manuals or controlling plant procedures.

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Waivers of QC inspections are annotated in procedures with the waiving QC  !

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inspector's initial, date, and QC waiver number. Of those MWR packages i

reviewed, the NRC inspector noted three QC inspections were waived. In

j subsequent review of QC documentation, it was found that during August 1-28, i

1988, 131 QC inspectior,s were scheduled. Of the 131 QC inspections, 124 l

J QC inspections were completed and 7 QC inspections waived. The NRC ,

inspector noted no specific written guidance existed concerning the r

criteria for waiver. Subsequent discussion with the QC manager revealed

! that, in general, QC inspection waivers were based upon inspector availability, ,

QC inspection essentially, and priority of the maintenance evolution,  ;

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(i.e., critical path element). Furthermore, it was noted that in those l

instances requiring postmaintenance testing, specific test instructions j

i were either stated in the MWR package or specifically referenced. Postmain- r

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tenance testing results were independently reviewed and documented. In general, l

4 the licensee's QC efforts appear to be adequate. Maintenance evolutions  !

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) affecting safety-related structures, systems, or components appear to be

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perfonned in a manner which ensures a quality level at least equivalent to

j that specified in the original design bases and requirements.

During the review of MWR packages, it was noted that certain inconsistencies f

exist between practices relative to simplified maintenance evolutions and  !

4 more con' plex, detailed evolutions. These inconsistencies are best characterized [

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as "inattention-to-detail" items on the craftsmen's part in recording data l

and to the involvement of maintenance section supervisors and QC personnel i

in review of MWR packages for completeness, f

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i The NRC inspector noted, as an example, MWR IL-49553, "Electrical l

! Penetration #EP-62 " corrpleted July 3, 1988. The MWR documents that the li

l penetration failed an in-service leak test (ISLT). However, the MWR

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package did not specifically reference the repair MWR or the postmaintenance

ISLT. The NRC inspector discussed this matter with key licensee personnel

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and stressed the importance of detailed documentation. (

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The licensee agreed that inclusion of specific references in the work

package facilitates ready tra eability. A subsequent review of documentation

by the licensee retrieved records of postmaintenance testing from the

onsite document control center. In this regard, the NRC inspector noted

that no specific guidance exists in the licensee's MWR Program

Procedure OPGP03-EM-0003, Revision 19, which delineates what the cognizant

maintenance division foreman should check when reviewing an MWR package

for completeness. The NRC inspector noted that the QC procedure for

closure of MWRs/PMCs/SWRs included a checklist used by operations quality

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assurance during the final package review.

During review of MWR Package RH-57765, the NRC inspector noted that the

i craftsmen failed to document the heat number for the No. 4 removed stud.

Recording the heat numbers of removed studs wu required by Step 18 of the

ASME Section XI repair and replacement traveler, R&R No 1-88-019. The

, failure to record the heat number is a concern that shall be identified

as an unresolved item (50-498/8862-01) pending further investigation by

the licensee. Other similar examples of inattention-to-detail and

inadequate review were provided to the licensee. The NRC inspector

discussed the inconsistencies with the licensee and indicated that such

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inconsistencies may be representative precursors to possible future

q program.atic problems.

6. Receipt of New Fuel at Reactor Facilities (81403) and (60502)

This portion of the inspection involved observation of the licensee's

procedural implementation for receipt of new fuel. The NRC inspector

verified that the licensee's physical security program provided satisfactory

! protection for new fuel upon receipt. Furthermore, the NRC inspector

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verified that the new fuel was inspected, assembled and stored in preparation

i for fuel loading in accordance with regulatory requirements, and FSAR

' commitments, license requirements, and procedural controls. The NRC

inspector observed craf tsmen and QC personnel unpacking new fuel bundles,

, perfonning visual inspection, and moving the new fuel bundles into temporary

storage while awaiting fuel loading. The licensee had established precautions

and the necessary measures to satisfy 10 CFR 73.67 and provided adequate

physical protection of the new fuel bundles while in transit. Procedural

controls were implemented for radiological controls to minimize personnel

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exposure and to limit and control foreign material in and around the fuel

assembly storage area. Unit 2 fuel handling building. The responsible

craftsmen established a foreign material exclusion (FME) area, controlled

entry of personnel, tools, and equipment by use of a control log. The use

of protective clothing and lanyarding of loose tools / items further prevented

loss of FME or possible damage to new fuel. The NRC inspector noted that

key personnel present during the new fuel receipt and storage were knowledgeable

of the procedural requirements and cautious in their actions.

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No violations or deviations were identified in the review of this program

area.

7. Exit Interview

The NRC inspectors met with the licensee personnel denoted in paragraph 1

on September 14, 1988 and October 14, 1988. The NRC inspectors sunrnarized

the scope and findings of the inspection. The licensee did not identify

as proprietary any of the infonnation provided to, or reviewed by the NRC

inspectors.

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Attachmer.t

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MWR packages reviewed:

HC-65955 RC-55463

DG-68864 DJ-45043

PE-56110 BR-87031683

AF-59855 PL-49058

RH-65259 AF-87033311

RH-65257 PK-68821

PL-65095 CH-66582 I

PM-87024920 IL-49553  ;

MS-59785 CM-66903 ,

RC-68875 BR-55515

DG-55348 PK-68305

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CV-69934 RH-57765

HS-66210 DG-68862 r

CV-65863 DG-87033314 I

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AF-69673 DG-52064 j

FP-87027058 RH-57764

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HE-59850 EW-58795

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